G.R. No. 122276 November 20, 2001
Rodrigo Almuete and Ana Almuete, petitioners, vs. Marcelo Andres and the Court of Appeals, respondents.

FACTS

Petitioner Rodrigo Almuete was the awardee of an agricultural land from NARRA in 1957 and possessed it exclusively for over two decades. In 1979, Agrarian Reform Technologist Leticia Gragasin filed a report falsely stating Almuete had abandoned the land and waived his rights, recommending the cancellation of his award. Based on this and unsubstantiated claims by respondent Marcelo Andres regarding an oral chain of sales, the Ministry of Agrarian Reform cancelled Almuete’s award and issued a homestead patent to Andres, leading to the issuance of OCT No. P-52521 in his name in 1988. Andres subsequently entered the property, destroyed crops, and took possession of half of it.
Almuete, discovering the fraud, filed an action for reconveyance and recovery of possession before the Regional Trial Court (RTC) of Cauayan, Isabela. The RTC ruled in Almuete’s favor, declaring him the owner, ordering reconveyance, and finding the cancellation and issuance of title to Andres were perpetrated through fraud. Andres did not appeal, making the RTC decision final. He later filed a petition for certiorari with the Court of Appeals (CA), arguing the RTC lacked jurisdiction as the case involved agrarian reform matters cognizable by the DAR Adjudication Board (DARAB).

ISSUE

Whether the Regional Trial Court had jurisdiction over the action for reconveyance and recovery of possession filed by the Almuetes.

RULING

Yes, the RTC had jurisdiction. The Supreme Court reversed the CA and reinstated the RTC’s final and executory decision. The Court clarified that jurisdiction is determined by the allegations in the complaint and the nature of the action. The principal issue raised was the validity of the homestead patent and certificate of title issued to Andres through fraud, and the consequent declaration of Almuete’s ownership. This is an action for reconveyance, which is inherently a judicial issue involving the investigation of title and falls within the exclusive jurisdiction of regular courts. The case did not involve a tenancy relationship or an agrarian dispute over agricultural leasehold, share tenancy, or other matters specifically placed under DARAB’s authority. The mere fact that the land is agricultural does not automatically divest the RTC of jurisdiction. Since the action was fundamentally about ownership and title acquired by fraud, it was correctly filed with the RTC. The Court also held that certiorari was improperly granted by the CA, as it cannot substitute for a lost appeal, which Andres forfeited by his failure to timely question the RTC judgment.